Wood v Revenue and Customs (INHERITANCE TAX - transfers of value - s.10 IHTA 1984 - whether intention to confer any gratuitous benefit on any person - exempt transfers - s.21 of IHTA 1984 - whether donations were part of normal expenditure) [2026] UKFTT 589 (TC) (16 April 2026)

Wood v Revenue and Customs (INHERITANCE TAX - transfers of value - s.10 IHTA 1984 - whether intention to confer any gratuitous benefit on any person - exempt transfers - s.21 of IHTA 1984 - whether donations were part of normal expenditure) [2026] UKFTT 589 (TC) (16 April 2026)

Mr Wood's payments objectively and subjectively conferred gratuitous benefits on the recipients, and he intended to improve their financial positions. The payments were not made pursuant to any settled pattern or prior commitment, but were ad hoc and discretionary. Therefore, s.10(1) does not apply to exclude the payments from being transfers of value, and s.21 does not apply to exempt them as normal expenditure out of income.

Citation
[2026] UKFTT 589 (TC)
Parties
Appellant: Jonathan Wood; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
16 April 2026
Procedural Posture
Tax Appeal (inheritance Tax) / First Tier Tribunal (tax Chamber) Final Judgment
Outcome
Appeal dismissed
Legal Topics
Inheritance Tax, Transfers of Value, Exempt Transfers, Normal Expenditure Out of Income, Intention to Confer Gratuitous Benefit
Tax Law Inheritance Tax Transfers of Value Exempt Transfers Normal Expenditure Out of Income Intention to Confer Gratuitous Benefit

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Parties

Jonathan Wood

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal (inheritance Tax) / First Tier Tribunal (tax Chamber) Final Judgment

Legal Issues

  1. 1 Whether the payments made by Mr Wood were intended to confer any gratuitous benefit under s.10 IHTA 1984
  2. 2 Whether the payments qualified as exempt transfers as part of normal expenditure under s.21 IHTA 1984

Ratio Decidendi

Mr Wood's payments objectively and subjectively conferred gratuitous benefits on the recipients, and he intended to improve their financial positions. The payments were not made pursuant to any settled pattern or prior commitment, but were ad hoc and discretionary. Therefore, s.10(1) does not apply to exclude the payments from being transfers of value, and s.21 does not apply to exempt them as normal expenditure out of income.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.
  • The Varied Determination of HMRC stands and the payments are chargeable to Inheritance Tax.